Transfer Pricing Blog

TPGenie + Public CbC

TPGenie is prepared to flag for Public Country by Country Reporting. Public CbC will be in place for the MNE groups. To determine if an MNE is flagged for Public CbC, TPGenie uses the below set of rules: EU headquartered MNE and in last 2 years revenue > 750mil, or...

How to perform a Transfer Pricing benchmarking study

Benchmarking study or comparability analysis is the heart of the application of the arm’s length principle. Application of the arm’s length principle is based on a comparison of the conditions in a controlled transaction with the conditions that would be applied...

ISO 27001 certification

Intra Pricing Solutions BV is in the process of ISO 27001 certification. The goal is to receive the certification by the end of 2022. What is ISO 27001 Certification? ISO 27001 is an internationally recognised specification for an Information Security Management...

Compare Transfer Pricing databases

Multinational enterprises across the globe have to comply with transfer pricing documentation requirements. To provide the documentation which is fully compliant with tax legislation it should contain the calculation of arm’s length range – comparability analysis. In...

What is a Transfer Pricing Policy template?

A transfer pricing policy template is a document that provides a framework for setting transfer pricing policies within an organization. Transfer pricing refers to the pricing of goods or services that are transferred between related parties, such as between different...

Benefits of using TPGenie and having an external tax advisor

When using TPGenie for creating local files for your MNE group entities, it could be that in some countries (for example India or China) you still have external tax advisors handling your transfer pricing documentation. How to deal with this in TPGenie? Is there a way...

What is the CbCR Survey?

What is the CbCR Survey?

Don't waste your time on sending back and forth Excels and lots of emails! TPGenie transfer pricing software is equipped with the CbCR Survey. The CbCR Survey is easy to use workflow software that enables you to gather your local CbC data across your group entities....

Dutch Country-by-Country Reporting specifications v4.0

Dutch Country-by-Country Reporting specifications v4.0

On April 21th 2021 the Dutch Tax Authorities released an update of specifications in the Country-by-Country Reporting Guide, version 4.0. The overview includes new specifications and updated XML schemas for the Dutch CbCR XML delivery. From August 4th 2021 it is only...

Attribution of profits to a permanent establishment

Attribution of profits to a permanent establishment

Transfer pricing with respect to permanent establishments deserves separate attention. Whereas the OECD guidelines are primarily aimed at transactions between legal entities, the allocation of profits to permanent establishments requires a different approach. Here it...